3
Shared Docs
3
Same-Page
3 / 3
Mentions
ircumstances may be held to prevent mere discovery, is not applicable in this instance, where Plaintiff has placed her past sexual history at issue. Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5 DCA 1997), rev. th denied,719 So.2d 286 (Fla. 1998)(allowing discovery of plaintiff’s employment history which incl
Fla. Feb. 19, 1999); P.J. Herchenroeder v. John Hopkins Univ. Applied Physical Lab, 171 F.R.D. 179 (D. Mad. 1997); Sanchez v. Zabihi, 166 F.R.D. 500 (D. N.M. 1996); and Stalnaker v. Kmart Corp., 1996 WL 397563 (D. Kan 1996). Plaintiff’s reliance on these cases in support of her position, however, is mispl
ording of the conduct which was the subject of the complaint, and a description of her damages. 703 So.2d 1077-78. At no time were the plaintiffs in Balas asked to disclose their entire sexually history beginning at age 10. Id. Thus, the three state court cases cited in the Motion are not helpful to t
ied Physical Lab 171 F.RD. 179 (D. Md. 1997) (looking at both Rule 26 and Rule 412 in resolving discovery motion); Sanchez Zabihi, 166 F.R.D. 500 (D. N.M. 1996) (explaining that "[a]lthough the present motion arises in the context -4- EFTA00222165 Case 9:08-cv-80119-KAM Document 93 Entered on FLSD
d 6 EFTA00222176 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05)06:2009 Page 7 of 10 1077-78. At no time were the plaintiffs in Balas asked to disclose their entire sexually history beginning at age 10. Id. Thus, the three state court cases cited in the Motion are not helpful to t
d Physical Lab, 171 F.RD. 179 (D. Md. 1997) (looking at both Rule 26 and Rule 412 in resolving discovery motion); Sanchez'. Zabihi, 166 F.R.D. 500 (D. N.M. 1996) (explaining that la]lthough the present motion arises in the context of discovery under Rule 26, the Court must remain mindful of Rule 412 an
Entities connected to both Balas and D. N.M.

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSONRobert D. Critton
PERSON
Kenneth Marra
PERSONHerron
PERSONBarta
PERSON
Alan Dershowitz
PERSONGibbons
PERSON
Oliver Stone
PERSONSanchez
PERSONStalnaker
PERSON
Honolulu
LOCATION
Scarlett Johansson
PERSONP.J. Herchenroeder
PERSONZabihi
PERSON
United States District Court
ORGANIZATIONJANE DOE NO.
PERSONSouthern District
LOCATIONOrdover
PERSON